https://www.taxtmi.com/caselaws?id=792142 Under section 115JB(2C), only amounts actually adjusted in other equity on the Ind AS convergence date can form the transition amount, and debentures without a demonstrated liability component cannot be treated as a compound financial instrument merely because of their accounting presentation. On the facts, the debentures issued to the holding company were not includible in the transition amount, so the MAT adjustment failed. For section 14A, Rule 8D cannot be applied mechanically unless the Assessing Officer first records dissatisfaction with the assessee's suo motu disallowance on the basis of the accounts. As that statutory precondition was absent, the disallowance was not sustainable. en-us Thu, 21 May 2026 00:00:00 +0530 Sat, 23 May 2026 08:27:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792142 Under section 115JB(2C), only amounts actually adjusted in other equity on the Ind AS convergence date can form the transition amount, and debentures without a demonstrated liability component cannot be treated as a compound financial instrument merely because of their accounting presentation. On the facts, the debentures issued to the holding company were not includible in the transition amount, so the MAT adjustment failed. For section 14A, Rule 8D cannot be applied mechanically unless the Assessing Officer first records dissatisfaction with the assessee's suo motu disallowance on the basis of the accounts. As that statutory precondition was absent, the disallowance was not sustainable. Case-Laws Income Tax Thu, 21 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792142